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“Section 2(24)(x)”

Section References (mined)Section 2Section 2(24)(x)1,421 judgments

The decision most relied on for Section 2(24)(x) is CIT v. AIMIL Ltd. (321 ITR 508), cited in 1,629 judgments on BharatTax.

Leading authorities on Section 2(24)(x)

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises
298 ITR 141 · 2008 · High Court
706
citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

(i) CIT v. Merchem Ltd.
378 ITR 443 · 2015 · High Court
631
citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

CIT v. Gujarat State Road Transport Corpn
41 Taxmann.com 100 · 2014 · High Court
540
citing judgments

Employees' contributions to provident fund or other welfare funds are deductible under section 36(1)(va) only if paid by the due date specified in the respective welfare fund enactments, and section 43B does not extend this period to the income tax return filing due date under section 139(1).

CIT v. State Bank of Bikaner & Jaipur
43 Taxmann.com 411 · 2014 · High Court
524
citing judgments

Employee contributions to provident fund, ESI, and other welfare funds, if deposited by the due date for furnishing the return of income under Section 139(1), are allowable as a deduction and cannot be disallowed under Section 36(1)(va) read with Section 2(24)(x) or Section 43B, even if deposited after the due date prescribed by the respective welfare Acts.

Judgments citing Section 2(24)(x)

Nse Clearing Ltd., Mumbai vs. DCIT, Circle-7(1)(1), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 3719/MUM/2023[2020-21]Status: DisposedITAT Mumbai07 Aug 2024AY 2020-21

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm A.Y.2020-21 Nse Clearing Limited Deputy Commissioner Of Exchange Plaza, Bandra Income Tax-Circle 7(1)(1), Kurla Complex, Bandra East, Mumbai Mumbai Vs.

Section 139(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 43B

Rs.5,71,518/- being contribution to the fund was added on account of provisions of section 36(1)(va) read with section 2(24)(x) of the Act without appreciating the fact that such amount is deposited before the due date of the respective fund and there was no delay

Tdi Infracorp (India) Ltd., New Delhi vs. ADIT, CPC, Bengaluru

The appeal of the assessee is dismissed

ITA 3714/DEL/2023[2021-22]Status: DisposedITAT Delhi06 Aug 2024AY 2021-22

Bench: Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2020-21 Tdi Infracorp (India) Ltd. Vs. Adit Upper Ground Floor 11, Cpc Bengaluru Tolstoy Marg, Connaught Vandana Building Place, Connaught Place, Delhi-110001 Pan No.Aacct41228 (Appellant) (Respondent) Appellant By Sh. Tarandeep Singh Ca Respondent By Sh. Amit Katoch Sr Dr Date Of Hearing: 25/07/2024 Date Of Pronouncement: 06/08/2024

Section 139(1)Section 143(1)Section 2(24)(x)Section 36Section 36(1)Section 36(1)(va)Section 43B(6)

crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee

Tdi Infrastructure Limited, Delhi vs. ADIT CPC, Bengaluru

The appeal of the assessee is dismissed

ITA 3713/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Aug 2024AY 2020-21

Bench: Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2020-21 Tdi Infrastructure Vs. Adit Limited D-92 Ground Floor Cpc Bengaluru Lajpat Nagar -1Delhi Pan No.Aaaci5799P (Appellant) (Respondent) Appellant By Sh. Tarandeep Singh Ca Respondent By Sh. Amit Katoch Sr Dr Date Of Hearing: 25/07/2024 Date Of Pronouncement: 06/08/2024

Section 139(1)Section 143(1)Section 2(24)(x)Section 36Section 36(1)Section 36(1)(va)Section 40Section 43B(6)

crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee

Tdi Infratech Limited, Delhi vs. ACIT Central Circle-27, Delhi

The appeal of the assessee is dismissed

ITA 3712/DEL/2023[2019-20]Status: DisposedITAT Delhi06 Aug 2024AY 2019-20

Bench: Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2019-20 Tdi Infratech Limited 10 Vs. Acit Shaheed Bhagat Singh Central Circle -27 Marg, New Delhi-110001 Delhi Pan No.Aabct3582A (Appellant) (Respondent) Appellant By Sh. Tarandeep Singh Ca Respondent By Sh. Amit Katoch Sr Dr Date Of Hearing: 25/07/2024 Date Of Pronouncement: 06/08/2024

Section 139(1)Section 143(1)Section 2(24)(x)Section 36Section 36(1)Section 36(1)(va)Section 40Section 43B(6)

crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee

Raja Udyog (P) Ltd., 24-Parganas (N) vs. ACIT, CC-4(3), Kol, Kolkata

In the result, I.T.(SS)A. No

ITA 944/KOL/2024[2017-18]Status: DisposedITAT Kolkata30 Jul 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.944/Kol/2024 Assessment Years: 2017-18 Raja Udyog (P) Ltd…..…………….....……………………....………....Appellant Sukchar Girja, 16F, Barrackpore Trunk Road, 24 Parganas (N), W.B – 700115. [Pan: Aaccr0764P] Vs. Acit, Cc-4(3), Kolkata…...................................................…..…..... Respondent I.T.(Ss)A. No.43/Kol/2024 Assessment Year: 2017-18 Raja Udyog (P) Ltd…..…………….....……………………....………....Appellant Sukchar Girja, 16F, Barrackpore Trunk Road, 24 Parganas (N), W.B – 700115. [Pan: Aaccr0764P] Vs. Acit, Cc-4(3), Kolkata…...................................................…..…..... Respondent I.T.(Ss)A. No.44/Kol/2024 Assessment Year: 2018-19 Raja Udyog (P) Ltd…..…………….....……………………....………....Appellant Sukchar Girja, 16F, Barrackpore Trunk Road, 24 Parganas (N), W.B – 700115. [Pan: Aaccr0764P] Vs. Acit, Cc-4(3), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Rajeeva Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Rakesh Kr. Das, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 29, 2024 Date Of Pronouncing The Order : July 30, 2024

Section 143(3)Section 250Section 36(1)(va)Section 40A(7)Section 43B

आयकर अपील"य अ"धकरण, कोलकाता पीठ ‘सी’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH KOLKATA Before Shri

Signet Industries Ltd., Maharashtra vs. NFAC, Delhi

Appeal is partly allowed

ITA 525/IND/2023[2013-2014]Status: DisposedITAT Indore30 Jul 2024AY 2013-2014

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2013-14 Signet Industries Limited, Nfac, Delhi / Gala No. 02 & 03, Acit, Central-1, Indore Buiding No. A-2, Ground Floor, Print World Industrial बनाम/ Complex, Vs. Village Vehele Bhindwadi, Shastri Nagar, Thane (Maharastra) (Assessee/Appellant) (Revenue/Respondent) Pan: Aabcs3489F Assessee By Shri Ajay Tulsiyan, C.A. & Ruchira Singhal, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 02.07.2024 Date Of Pronouncement 30.07.2024

Section 143(2)Section 143(3)Section 14ASection 36(1)(va)

Ground No. 2: 8. This ground relates to the disallowance of Rs. 99,564/- made by AO u/s 36(1)(va) read with section 2(24)(x) on account of employees’ contributions to Provident Fund collected by assessee but not deposited to Provided Fund upto due dates prescribed under relevant

Magic Software Pvt. Ltd., New Delhi vs. DCIT Circle 16(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 654/DEL/2024[2022-23]Status: DisposedITAT Delhi29 Jul 2024AY 2022-23

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Usassessment Year 2022-23

For Respondent: Shri Jatender Kumar Kale, CIT-DR
Section 143(1)Section 2(24)(x)Section 36(1)(va)

assessee concerns disallowance of employees’ contribution to Provident Fund on the contours of Section 36(1)(va) of the Act r.w. Section 2(24)(x) of the Act. 3. When the matter was called for hearing, the ld. counsel for the assessee submitted at the outset that the assessee ... involves disallowance of the employees’ contribution to PF relatable to wages for May, 2021 on the contours of Section 36(1)(va) r.w. Section 2(24)(x) of the Act owing to one day delay in deposit of Employees’ Contribution. As amply demonstrated 4 on behalf of the assessee

Kanwar Enterprises Private Limited, Delhi vs. ACIT, Circle-14(1), Delhi

In the result, the appeal of the assessee is dismissed

ITA 169/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Jul 2024AY 2018-19

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Ms. Parul Singh, Sr. DR
Section 145(2)Section 2(24)(x)Section 3Section 36(1)Section 36(1)(va)Section 43

dates under the relevant provisions of the Act. The Assessing Officer ruled that by virtue of Section 36(1)(va) read with Section 2(24)(x) of the IT Act, such sums received by the appellants constituted "income". It was held that those amounts could not have been allowed

Ultimate International Private Limited, Delhi vs. The Asst. Commissioner of Income Tax, Bangaluru, Delhi

In the result, the appeal of the assessee is dismissed

ITA 2780/DEL/2023[2020-21]Status: DisposedITAT Delhi29 Jul 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: NoneFor Respondent: Sh. Amit Katoch, Sr. DR
Section 143(1)Section 2(24)(x)Section 36(1)(va)

dates under the relevant provisions of the Act. The Assessing Officer ruled that by virtue of Section 36(1)(va) read with Section 2(24)(x) of the IT Act, such sums received by the appellants constituted "income". It was held that those amounts could not have been allowed

Diamour Jewels Private Limited, Andheri East, Mumbai vs. CPC, Bengaluru

In the result, appeal of the assessee is allowed

ITA 1965/MUM/2024[2021-22]Status: DisposedITAT Mumbai25 Jul 2024AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Ms. Krupali Mehta, CAFor Respondent: Smt. Mahita Nair, Sr. DR
Section 143(1)Section 250Section 36(1)(va)

Court in para 35 and 52 took note of the memorandum explaining the provisions in the Finance Bill, 1987 through which section 2(24)(x), section 36(1)(va) and second proviso to section 43B were introduced. It was observed that “these provisions were introduced to ensure timely payments were

Khimji Ramdas India Private Limited, Ahmedabad vs. The ITO, Ward-2(1)(2) Present Juridiction the DCIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 500/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad24 Jul 2024AY 2014-15

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita No.500/Ahd/2023 िनधा"रण वष"/Assessment Year: 2014-15 बनाम बनाम बनाम बनाम Khimji Ramdas India Pvt. Ltd., The Ito, Ward-2(1)(2), 2Nd Floor, City Square Godrej Ahmedabad, Vs. Garden City, Jagatpur, Present Jurisdiction Ahmedabad-382470 The Dcit, Pan : Aadck 6056 C Circle-2(1)(1), Ahmedabad अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) िनधा"रती की ओर से / Assessee By : Shri Aatish Shah, Ar & Shri Anil N. Shah, Ar ""थ" की ओर से / Revenue By: Shri Hishikes Hemant Patki, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 22/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 24/07/2024 आदेश आदेश/O R D E R आदेश आदेश The Present Appeal Has Been Filed By The Assessee Against Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short Referred To As “Ld. Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 [In Short Referred To As “The Act”] Dated 12.05.2023 Pertaining To Assessment Year (Ay) 2014-15. 2. Grounds Raised Are As Under:- “1. The Ld. Ao Wd. 2(1)(2) Has Erred In Law & On Facts In Passing The Impugned Order Which Is Bad In Law & Liable To Be Quashed & The Ld. Cit(Appeals) Have Similarly Cit(A) Have Erred In Law & On Facts In Confirming The Impugned Order Vide His Order Passed Us.250 Of The Income Tax Act, 1961 In Appeal Vide His Order Dtd.12-05-2023 Din & Order No.Itba/Nfac/S/250/2023-24/1052777862(1) Dtd. 12/05/2023. 2. The Ld. Cit(A) Has Erred In Law & On Facts Without Considering/Adjudicating

For Appellant: Shri Aatish Shah, AR &For Respondent: Shri Hishikes Hemant Patki, Sr DR
Section 154Section 250Section 36(1)(va)

been disclosed in the Tax Audit Report filed by the assessee in Form No. 3CD, was not disallowed in terms of provisions of Section 2(24)(x) r.w.s. 36(1)(va) of the Act. The quantum of such disallowance noted by the Assessing Officer was Rs.27,19,302/-; the details ... issue of disallowance of employees’ contributions to ESI and PF amounting to Rs.27,19,302/- made in terms of provisions of Section 2(24)(x) r.w.s. 36(1)(va) of the Act in the order passed u/s 154 of the Act has not been considered by either of the authorities

Reliable Automotive Private Limited, Mumbai vs. CIT(A), Addl/JCIT(A)-1, Coimbatore

Appeal of the assessee is allowed for statistical purpose

ITA 4479/MUM/2023[2019-20]Status: DisposedITAT Mumbai22 Jul 2024AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm Reliable Automotive Private Cit (A), Addl/ Jcit (A)-1 Limited Circle 15(3)(1), Room Plot No. 29, Sector 1, No.460, Vs. 4Th Floor, Aaykar Bhavan, Shirwane Gaon, Nerul, Navi Mumbai-400 706 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaca9737D

For Appellant: ShriFor Respondent: Shri Rajesh Meshram, DR
Section 143(1)Section 143(1)(a)Section 154Section 2(24)(x)Section 250Section 36(1)

Department. 2) The Learned Commissioner of Income Tax (Appeals) has erred in disallowing of Rs.35,61,884/- u/s.36(1) (va) read with section 2(24)(x) of the Income Tax Act, on the ground of delays in payment of employees contribution to PF & ESIC ignoring the fact that: a) Payment

M/S. Checkmate Services Pvt. Ltd., Vadodara vs. The ADIT, CPC, Bangalore Present Juridiction the Dy. CIT, Circle-1(1)(1), Vadodara

In the result, appeal preferred by the assessee is dismissed

ITA 69/AHD/2023[2019-20]Status: DisposedITAT Ahmedabad16 Jul 2024AY 2019-20

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 69/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2019-20) िनधा"रण वष" िनधा"रण वष" M/S. Checkmate Adit, Cpc, बनाम बनाम/ बनाम बनाम Services Pvt. Ltd. Bangalore Vs. G.F 6-9, Amaan Tower & Suvas Colony, Fatehgunj, Dy.Cit Vadodara, Gujarat, Circle-1(1)(1), Vadodara 390002 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacc8465A (Appellant) .. (Respondent) Shri M. R. Sahu, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr 12/07/2024 Date Of Hearing Date Of Pronouncement 16/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’) Dated 08.12.2022 For The Assessment Year 2019-20. 2. The Brief Facts Of The Case Are That Assessee Had Filed Its Return Of Income For A.Y. 2019-20 On 30.09.2019 Declaring Total

For Respondent: Dr. Darsi Suman Ratnam, CIT. DR
Section 143(1)Section 143(1)(a)

former forms part of the employers' income, and the later retains its character as an income (albeit deemed), by virtue of section 2(24)(x) and therefore, subjected to conditions spelt out by Explanation to section 36(1)(va) i.e., depositing such amount received or deducted from the employee

Guljeet Singh Saroya, Gurugram vs. ITO, Ward 1 (4), Gurugram

The appeal of the assessee is dismissed

ITA 1022/DEL/2023[2020-21]Status: DisposedITAT Delhi11 Jul 2024AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2020-21

Section 143(1)Section 143(3)Section 154Section 2(24)Section 36(1)Section 37Section 43B

2. The Id. CIT(A) grossly erred on facts and in law in misreading the provisions o f Section 36(1) (va) r.w. Section 2(24) (x) r.w. Section 43B r.w. various legal decisions, as applicable for A Y 2020-21 and upholding the disallowance ... approach indicated in the riding in Alom Extrusions. As noticed previously, Alom Extrutions did not consider the fact of the introduction of Section 2(24) (x) or in fact the other provisions of the Act. 52. When Parliament introduced Section 43B, what was on the statute book, was only employers

Microsoft Corporation (India) Private Limited, New Delhi vs. Joint Commissioner of Income Tax, Special Range - 6, Delhi

In the result, the appeal filed by the Revenue is dismissed and the appeal of the assessee is allowed for statistical purposes

ITA 3671/DEL/2023[2015-16]Status: DisposedITAT Delhi09 Jul 2024AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2015-16 Acit, 16(1), Vs Microsoft Corporation (India) New Delhi. Pvt. Ltd., 807, New Delhi House, New Delhi – 110 001. Pan: Aaacm5586C Assessment Year: 2015-16 Microsoft Corporation (India) Pvt. Vs. Jcit, Ltd., Special Range-6, 807, New Delhi House, Delhi. New Delhi – 110 001. Pan: Aaacm5586C

For Appellant: Shri Nageshwar Rao &For Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(2)Section 143(3)Section 2(24)(x)Section 32Section 36(1)(va)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : D : NEW DELHIi BEFORE SHRI G.S. PANNU, HON’BLE VICE PRESIDENT AND

ACIT, 16(1), New Delhi vs. Microsoft Corporation (India) Pvt. Ltd, New Delhi

In the result, the appeal filed by the Revenue is dismissed and the appeal of the assessee is allowed for statistical purposes

ITA 3616/DEL/2023[2015-16]Status: DisposedITAT Delhi09 Jul 2024AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2015-16 Acit, 16(1), Vs Microsoft Corporation (India) New Delhi. Pvt. Ltd., 807, New Delhi House, New Delhi – 110 001. Pan: Aaacm5586C Assessment Year: 2015-16 Microsoft Corporation (India) Pvt. Vs. Jcit, Ltd., Special Range-6, 807, New Delhi House, Delhi. New Delhi – 110 001. Pan: Aaacm5586C

For Appellant: Shri Nageshwar Rao &For Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(2)Section 143(3)Section 2(24)(x)Section 32Section 36(1)(va)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : D : NEW DELHIi BEFORE SHRI G.S. PANNU, HON’BLE VICE PRESIDENT AND

Indaco Jeans Private Limited, Goregoan East vs. Ward 6(3)(2), Aayakrbhavan

In the result, the appeal of the assessee vide

ITA 80/MUM/2024[2015-16]Status: DisposedITAT Mumbai05 Jul 2024AY 2015-16

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Ashwin ChhagFor Respondent: H.M. Bhatt
Section 143(2)Section 143(3)Section 154Section 2(24)(x)Section 250Section 36(1)(va)Section 43B

P a g e | 1 ITA Nos.79 & 80/Mum/2024 Indaco Jeans Pvt. Ltd. Vs. ITO-6(3)(2) IN THE INCOME

Indaco Jeans Private Limited, Goregaon East vs. I.T.O 6(3)(2), Aayakar Bhavan

In the result, the appeal of the assessee vide

ITA 79/MUM/2024[2015-16]Status: DisposedITAT Mumbai05 Jul 2024AY 2015-16

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Ashwin ChhagFor Respondent: H.M. Bhatt
Section 143(2)Section 143(3)Section 154Section 2(24)(x)Section 250Section 36(1)(va)Section 43B

P a g e | 1 ITA Nos.79 & 80/Mum/2024 Indaco Jeans Pvt. Ltd. Vs. ITO-6(3)(2) IN THE INCOME

Jila Sahakari Kendriya Bank Maryadit, Khargone vs. The Income Tax Officer National Faceless Assessment Centre, Delhi

Appeal of the assessee is dismissed”

ITA 180/IND/2024[2022-23]Status: HeardITAT Indore01 Jul 2024AY 2022-23

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2022-23 Jila Sahakari Kendriya Cpc / Nfac Bank Maryadit, बनाम/ 33,Khandwa Road, Vs. Khargone (Assessee/Appellant) (Revenue/Respondent) Pan: Aaatj0529K Assessee By Shri Subhash Jain, Ar Revenue By Shri Ram Kumar Yadav, Cit Dr Shri Ashish Porwal, Sr. Dr Date Of Hearing 27.06.2024 Date Of Pronouncement 01.07.2024

Section 14BSection 154Section 2(24)(x)Section 36(1)(va)

issue involved in present appeal is the disallowance of Rs. 27,58,025/- made by AO u/s 36(1)(va) read with section 2(24)(x) on account of employees’ contribution to Provident Fund (P.F.) collected by assessee but not deposited upto the due date under

Sri. Amit Kumar Rajendra Prasad Singh, Bengaluru vs. Income Tax Officer, Ward-7(2)(3), Bengaluru

In the result, the appeal filed by the assessee is partly allowed

ITA 306/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Jun 2024AY 2020-21

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri V. Parithivel, JCIT-DR
Section 139Section 143Section 234ASection 250Section 36

additional evidences filed by both the assessees before us. 8.2 The ld. A.R. placed following arguments in respect of this contention: 2.1 “Section 2(24)(x) of the Act deems that the sums received by an assessee from his employees as contributions to any welfare fund, shall be treated ... same cannot be treated as the income of the assessee. Section 36(1)(va) provides a deduction of sums referred to in section 2(24)(x), if the such sum is credited by the assessee to the employee’s account in the relevant fund on or before the due date